decision of Hon'ble Supreme Court
in the case of Mak Data Pvt. Ltd. Vs. CIT reported in 358 ITR 593
is applicable. Referring ... rejoinder submitted
that the decision in the case of Mak Data (P) Ltd. (Supra) is
distinguishable and not applicable to the facts of the present
Supreme Court in the case of MAK Data (P) Ltd. vs. CIT-II 38
Taxman 448(SC) whereby the Hon'ble Apex Court held ... decision of the Hon‟ble Supreme Court in the case of
MAK Data (P) Ltd. Vs. CIT-II , 38 Taxman
held that "the principles laid down
in the case of MAK DATA Pvt. Ltd., Vs. CIT 358 ITR 593 are not
applicable ... recording a finding that the decision of the Supreme
Court, in MAK DATA P. Ltd. , (supra) is applicable to the facts of
assessee
Supreme Court in the case of MAK Data (P.) Ltd. Vs. CIT reported in
ITA No.1327/PUN/2016
5 Manoj S. Gugale ... Supreme Court in the case of MAK Data (P.) Ltd. Vs. CIT (supra).
9. We have heard the rival contentions and perused the record
Supreme Court in the case of
Mak data Pvt. Ltd. Vs. CIT vide Civil Appeal No.9772/2013 he submitted
that ... Supreme
Court in the case of Mak data Pvt. Ltd. (Supra) is not applicable. He
submitted that due to typographical error the mistake has happened
further pressing into service the decision in the
case of 'MAK Data Pvt. Ltd. Vs CIT ' [reported in 358 ITR 598 (SC)] dislodged ... Supreme
Court in the case of 'MAK Data Pvt Ltd Vs CIT ' (supra) observed that, the
explanation to section 271(1) raises
decision of Hon'ble Supreme Court in the case of
MAK Data Pvt. Ltd., vs. CIT [2013] 358 ITR 593 (SC), decision ... judgment of the Hon'ble Supreme Court
in MAK Data Pvt. Ltd. Vs. CIT (2013) 358 ITR 593 (SC) for bolstering his
submission that
further pressing into service the decision in the
case of 'MAK Data Pvt. Ltd. Vs CIT ' [reported in 358 ITR 598 (SC)] dislodged ... Supreme
Court in the case of 'MAK Data Pvt Ltd Vs CIT ' (supra) observed that, the
explanation to section 271(1) raises
further pressing into service the decision in the
case of 'MAK Data Pvt. Ltd. Vs CIT ' [reported in 358 ITR 598 (SC)] dislodged ... Supreme
Court in the case of 'MAK Data Pvt Ltd Vs CIT ' (supra) observed that, the
explanation to section 271(1) raises
ratio laid down by the Hon'ble Supreme Court in Mak Data Pvt. Ltd. Vs.
CIT (2013) 358 ITR 593 (SC) and observed that ... order and the ratio laid down by the Apex Court in Mak Data Pvt.
Ltd. Vs. CIT (supra).
10. We have heard the rival contentions
